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equests for interview with persons who are no longer employed by the Justice Department. For example, I have sent letters to both Bruce Reinhart and Alex Acosta, who both have information about the Epstein case, requesting an opportunity to discuss the case with them. Both of them have ignored my letters.
arlong assault on the prosecution and the prosecutors." Shortly thereafter, Jeffrey Epstein's defense attorney Roy Black sent a responsive letter to Alexander Acost's letter to the news media in which he claimed that he did not pry into the personal lives of prosecutors but merely pointed out misconduct and over-
of 64 why the U.S. Attorney's Office would have withheld notifications from the victims about the NPA. If the prosecutors were being assaulted, as Acosta has said they were, then they would have reason to disregard their obligations to crime victims. In addition, this would show improper behavior by
ness address. However, I did not have any direct way of contradicting sworn statement. Since then, however, in answering the victims' Requests for Admissions, the Government has admitted that it possesses information that learned confidential, non-public information about the Epstein case and that he di
y voluntary requests for interview with persons who are no Ion er employed by the Justice Department. For example, I have sent letters to both and Alex Acosta, who both have information about the Epstein case, requesting an opportunity to discuss the case with them. Both of them have ignored my letters.
arlong assault on the prosecution and the prosecutors." Shortly thereafter, Jeffrey Epstein's defense attorney Roy Black sent a responsive letter to Alexander Acost's letter to the news media in which he claimed that he did not pry into the personal lives of prosecutors but merely pointed out misconduct and over-
of 64 why the U.S. Attorney's Office would have withheld notifications from the victims about the NPA. If the prosecutors were being assaulted, as Acosta has said they were, then they would have reason to disregard their obligations to crime victims. In addition, this would show improper behavior by
iness address. However, I did not have any direct ■ of contradicting sworn statement. Since then, however, in answering the victims' Requests for Admissions, the Government has admitted that it possesses information that learned confidential, non-public information about the Epstein case and that he di
equests for interview with persons who are no longer employed by the Justice Department. For example, I have sent letters to both Bruce Reinhart and Alex Acosta, who both have information about the Epstein case, requesting an opportunity to discuss the case with them. Both of them have ignored my letters.
arlong assault on the prosecution and the prosecutors." Shortly thereafter, Jeffrey Epstein's defense attorney Roy Black sent a responsive letter to Alexander Acost's letter to the news media in which he claimed that he did not pry into the personal lives of prosecutors but merely pointed out misconduct and over-
of 64 why the U.S. Attorney's Office would have withheld notifications from the victims about the NPA. If the prosecutors were being assaulted, as Acosta has said they were, then they would have reason to disregard their obligations to crime victims. In addition, this would show improper behavior by
ss. However, I did not have any direct way of contradicting Reinhart's sworn statement. Since then, however, in answering the victims' Requests for Admissions, the Government has admitted that it possesses information that Reinhart learned confidential, non-public information about the Epstein case and th
rivileged — have been produced to opposing counsel]); signed Non- Prosecution Agreement, Addendum, and operative portion of 12/19/2007 Sanchez- Acosta letter (P-008328-P-008343 [not being withheld as privileged — have been produced to opposing counsel]); subfolder entitled "12/19/07 Acosta-Sanche
older entitled "Meeting Timeline" containing Villafaria typed notes summarizing meetings with opposing counsel prepared at request of R. Alexander Acosta, with handwritten correction and typed guideline estimate Work product Deliberative process Inadequate Log; No Factual Underpinnings; Fiduciar
ry Duty; Claims Against Public Prosecutor, Overriding Need; Attorney Conduct at Issue Waiver Suppl. Box 3 P-013850 E-mail, Marie Villafana to Alex Acosta, Andrew Lourie, Rolando Garcia, Karen Atkinson, and John McMillan, September 18, 2007, 9:31 a.m., RE: Epstein Negotiations Atty work-product
ss. However, I did not have any direct way of contradicting Reinhart's sworn statement. Since then, however, in answering the victims' Requests for Admissions, the Government has admitted that it possesses information that Reinhart learned confidential, non-public information about the Epstein case and th
de the realm of the attorney's work product, or any attorney-client privilege. Id. (citations omitted). The deposition of the former U.S. Attorney, R. Alexander Acosta, should not be permitted. As the U.S. Attorney, he would not have been involved in direct consultation with victims or their representatives. Moreo
such scrutiny ... so the integrity of the administrative process must be equally respected." Id. at 422 (citations omitted). Any deposition of Mr. Acosta by petitioners would present a substantial risk that petitioners would seek to dissect and question every factor considered by Mr. Acosta in decidin
Document 359 Entered on FLSD Docket 02/01/2016 Page 2 of 11 (December 2, 2015) seeks eleven categories of documents. Petitioners' First Request for Admissions sought admissions on twenty-six (26) assertions. Their Second Request for Admissions sought admissions on twenty-eight (28) assertions. The Third R
s," as alleged by former U.S. Attorney Alexander Acosta. See DE 266 at 12.13 Issues pertaining to motive
es revolving around whether the defense team engaged in a "yearlong assault on the prosecution and prosecutors," as alleged by former U.S. Attorney Alexander Acosta. See DE 266 at 12.13 Issues pertaining to motive can always be pursued, particularly when a case is in an early discovery phase. See, e.g., Gelabert
ted that it possessed information contradicting Reinhart's sworn affidavit. See DE 225.1 at 9-10, ¶¶ 43-45 ("in answering the victims' Requests for Admissions, the Government has admitted that it possess information that Reinhart leamed confidential non-public information about the Epstein case and he disc
es revolving around whether the defense team engaged in a "yearlong assault on the prosecution and prosecutors," as alleged by former U.S. Attorney Alexander Acosta. See DE 266 at 12." Issues pertaining to motive can always be pursued. particularly when a case is in an early discovery phase. See. e.g.. Gelahert
s," as alleged by former U.S. Attorney Alexander Acosta. See DE 266 at 12." Issues pertaining to motive
itted that it possessed information contradicting Reinhart's sworn affidavit. See DE 225-I at 9-10, 43-45 ("in answering the victims' Requests for Admissions, the Government has admitted that it possess information that Reinhart learned confidential non-public information about the Epstein case and he dis
e interests of the United States, the State of Florida, and the Defendant will be served by the following procedure; THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecu
ure; THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern Distric
ring Bates Nos. P-009712 thru P-009819; A copy of the Privilege Log that was filed with the Court; and A copy of the Responses to your Requests for Admissions that were filed with the Court. Please let me know if you have any difficulties with any of the copies. Sincerely, Wifredo A. Ferrer U Atto ey
Entities connected to both Alexander Acosta and Admissions

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
A. Marie Villafana
PERSON
United States
LOCATION
Jay Lefkowitz
PERSON
Jeffrey Sloman
PERSON
Kenneth Marra
PERSONLeon Black
PERSONthe Southern District
LOCATIONJack Goldberger
PERSONFBI
ORGANIZATION
Bradley Edwards
PERSONSouthern District
LOCATIONJane Doe
PERSON
Prince Andrew
PERSON
George W. Bush
PERSONRoy Black
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Dexter Lee
PERSON